Report to the Chairman, Subcommittee 

on National Security, Emerging 

Threats, and International Relations, 

Committee on Government Reform, 

House of Representatives 

United States General Accounting Office 

GAO 

May 2003 NUCLEAR SECURITY 

NNSA Needs to Better 

Manage Its Safeguards 

and Security Program 

GAO-03-471 
NNSA has not been fully effective in managing its safeguards and security 

program in four key areas. As a result, NNSA cannot be assured that its 

contractors are working to maximum advantage to protect critical facilities 

and material from individuals seeking to inflict damage. The four areas are 

as follows: 

• Defining clear roles and responsibilities. NNSA still has not fully 

defined clear roles and responsibilities for its headquarters and site 

operations.

• Assessing sites’ security activities. Without a stable and effective 

management structure and with ongoing confusion about roles and 

responsibilities, inconsistencies have emerged among NNSA sites on 

how they assess contractors’ security activities. Consequently, 

NNSA cannot be assured that all facilities are subject to the 

comprehensive annual assessments that DOE policy requires.

• Overseeing contractors’ corrective actions. To compound the 

problems in conducting security assessments, NNSA contractors do 

not consistently conduct required analyses in preparing corrective 

action plans. As a result, potential opportunities to improve physical 

security at the sites are not maximized because corrective actions 

are developed without fully considering the problems’ root causes, 

risks posed, or cost versus the benefit of taking corrective action.

• Allocating staff. NNSA has shortfalls at its site offices in the total 

number of staff and in expertise, which could make it more difficult 

for site offices to effectively oversee security activities.

Security Force in Action 

The attacks of September 11, 2001, 

intensified long-standing concerns 

about the adequacy of safeguards 

and security at four nuclear 

weapons production sites and three 

national laboratories that design 

nuclear weapons—most of these 

facilities store plutonium and 

uranium in a variety of forms. 

These facilities can become targets 

for such actions as sabotage or 

theft. The Department of Energy 

(DOE) and the National Nuclear 

Security Administration (NNSA)—a

separately organized agency within 

DOE—are responsible for these 

facilities. NNSA plays a crucial 

role in managing the contractors 

operating many of these facilities 

to ensure that security activities 

are effective and in line with 

departmental policy. GAO 

reviewed how effectively NNSA 

manages its safeguards and 

security program, including how it 

oversees contractor security 

operations. 

GAO is making four 

recommendations to the Secretary 

of Energy and the Administrator of 

NNSA to focus more on certain key 

management and oversight issues. 

Commenting on the draft report, 

NNSA disagreed with GAO’s 

conclusion that NNSA was not 

ensuring the comprehensive, 

annual assessments of contractors’ 

performance that DOE policy 

requires. GAO continues to believe 

that NNSA’s current efforts do not 

ensure conformance to DOE 

policy. 

www.gao.gov/cgi-bin/getrpt?GAO-03-471.

To view the full report, including the scope 

and methodology, click on the link above. 

For more information, contact Robin M. 

Nazzaro at (202) 512-3841 or 

nazarror@gao.gov. 

Highlights of GAO-03-471, a report to the 

Chairman, Subcommittee on National 

Security, Emerging Threats, and 

International Relations, Committee on 

Government Reform, House of 

Representatives 

May 2003

NUCLEAR SECURITY 

NNSA Needs to Better Manage Its 

Safeguards and Security Program 
Page i GAO-03-471 Nuclear Security 

Letter 1

Results in Brief 4

Background 7

NNSA’s Lack of Safeguards and Security Direction in Key Areas 

Results in Inconsistent Management of Contractors 9

Conclusions 16

Recommendations for Executive Action 16

Agency Comments and Our Evaluation 17

Appendix I Comments from the National Nuclear Security 

Administration 20 

Appendix II GAO Contact and Staff Acknowledgments 23 

Abbreviations 

DOE Department of Energy 

FRAM Functions, Responsibilities, and 

Authorities Manual

NNSA National Nuclear Security Administration 

Contents 

This is a work of the U.S. Government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. It may contain copyrighted graphics, images or other materials. 

Permission from the copyright holder may be necessary should you wish to reproduce 

copyrighted materials separately from GAO’s product. 
Page 1 GAO-03-471 Nuclear Security 

May 30, 2003 

The Honorable Christopher Shays 

Chairman, Subcommittee on National Security, 

 Emerging Threats, and International Relations 

Committee on Government Reform 

House of Representatives 

Dear Mr. Chairman: 

Over the past decade, we and others have raised concerns about the 

adequacy of security at nuclear weapons facilities within the Department 

of Energy (DOE) and the National Nuclear Security Administration 

(NNSA)—a separately organized agency within DOE. For example, we 

reported in 2002 that DOE had not addressed problems in implementing 

security initiatives,1

 while an independent study by the Commission on 

Science and Security,2

 conducted at the request of DOE, found deficiencies 

in cyber security. Concerns over security within the nuclear weapons 

complex were brought into sharper focus by the September 11, 2001, 

terrorist attacks. These attacks highlighted the importance of effective 

physical security3

 in response to a potentially large and well-organized 

threat. 

NNSA relies upon its safeguards and security program to ensure the 

physical security of the nation’s nuclear weapons complex. Currently, the 

complex has four production sites: the Pantex Plant, Amarillo, Texas; the 

Y-12 Plant, Oak Ridge, Tennessee; the Kansas City Plant, Kansas City, 

Missouri; and the Savannah River Site, Aiken, South Carolina. In addition 

to the production sites, the complex includes the Nevada Test Site and 

three national laboratories that design nuclear weapons: Lawrence 

 1

 U.S. General Accounting Office, Nuclear Security: Lessons to Be Learned from 

Implementing NNSA’s Security Enhancements, GAO-02-358 (Washington, D.C.: March 29, 

2002). 

2

 Commission on Science and Security, Center for Strategic and International Studies, 

Science and Security in the 21st Century: A Report to the Secretary of Energy on the 

Department of Energy Laboratories (Washington, D.C.: Apr. 2002). 

3

 Physical security is the combination of operational and security equipment, personnel, 

and procedures used to protect facilities, information, documents, or material against theft, 

sabotage, diversion, or other criminal acts. 

United States General Accounting Office

Washington, DC 20548 
Page 2 GAO-03-471 Nuclear Security 

Livermore National Laboratory, Livermore, California; Los Alamos 

National Laboratory, Los Alamos, New Mexico; and the Sandia National 

Laboratories, Albuquerque, New Mexico, and Livermore, California. To 

implement its safeguards and security program, NNSA relies on site 

contractors that are responsible for conducting day-to-day security 

activities and adhering to DOE policies as they operate the complex’s 

laboratory and production facilities. The contractors’ activities are subject 

to DOE-NNSA oversight. NNSA has offices—site offices—co-located with 

each site. Many of these sites possess Category I special nuclear material. 

Category I material includes plutonium and uranium in the following 

forms: (1) assembled nuclear weapons and test devices; (2) products 

containing higher concentrations of plutonium or uranium, such as major 

nuclear components, and recastable metal; and (3) high-grade materials, 

such as carbides, oxides, solutions, and nitrates. The risks this radioactive 

material poses vary, but include the potential for sabotage, or theft for 

illegal use in a nuclear weapon. Because these materials pose such risks, 

NNSA’s management of the safeguards and security program, which 

includes overseeing contractor activities, is essential to preventing an 

unacceptable, adverse impact on national security. 

DOE’s Office of Security develops and promulgates orders and policies 

that guide NNSA’s safeguards and security program. NNSA is responsible 

for ensuring that its contractors’ security activities are effective and 

conform to DOE’s orders and policy requirements. In conducting this 

oversight, NNSA generally uses certain key processes intended to identify 

specific weaknesses at contractor-operated sites and ensure that 

weaknesses are corrected. These processes include, among other things, 

(1) annual, comprehensive surveys conducted by subject matter experts 

from across the complex and (2) ongoing reviews of one or more aspects 

of contractors’ program (surveillance) by NNSA site officials.4

DOE’s Office of Independent Oversight and Performance Assurance also 

assesses contractor security activities. In response to NNSA surveys and 

assessments conducted by the Office of Independent Oversight and 

Performance Assurance, DOE policy requires contractors to prepare 

corrective action plans for identified problems and to ensure that these 

 4

 A surveillance is generally conducted by a single or small number of subject matter 

experts, and the documentation from a surveillance or group of surveillance activities may 

be used as part of the survey. 
Page 3 GAO-03-471 Nuclear Security 

actions are based on documented root cause analysis, risk assessment, 

and cost-benefit analysis. 

You asked us to review physical security at NNSA and DOE facilities that 

contain Category I materials. Specifically, as agreed with your office, this 

report examines how NNSA manages its safeguards and security program. 

This report is the first of two that we will be issuing to you on various 

aspects of physical security at NNSA and DOE facilities. Our followup 

report will focus on the extent to which physical security has improved; 

the effectiveness of the process for establishing safeguards and security 

requirements following the September 11, 2001, attacks; and the remaining 

vulnerabilities. 

To evaluate the overall safeguards and security oversight process, we 

reviewed DOE policy and planning documents, including orders, 

implementation guidance, and reports. We looked at what the orders and 

guides prescribed, particularly DOE Order 470.1, and compared this to 

how operations and site offices were following and implementing the 

policies to see if there were any deficiencies. To determine how NNSA 

organizes and conducts overall safeguards and security oversight, we met 

with officials from DOE and NNSA headquarters and NNSA site offices. 

The primary offices from which we obtained information were from DOE’s 

Office of Security, Office of Independent Oversight and Performance 

Assurance, and NNSA’s Office of Defense Nuclear Security and Nuclear 

Safeguards and Security Program.5

 We also evaluated the NNSA 

reorganization with regard to the potential impact on oversight roles and 

responsibilities of NNSA headquarters and site offices. 

We visited 7 site offices from March 2002 to October 2002, to determine 

how federal contractor oversight and the safeguards and security program 

is managed. Specifically, we visited Los Alamos National Laboratory and 

the Office of Los Alamos Site Operations in New Mexico, Sandia National 

Laboratory and the Office of Kirtland Site Operations in New Mexico, 

Department of Energy’s Albuquerque Operations Office in New Mexico, 

the Office of Transportation Safeguards in New Mexico, Y-12 Plant, and 

the Y-12 Site Office in Tennessee, Pantex Plant and the Office of Amarillo 

 5

 We did not include naval reactors in our review because it is a semiautonomous entity 

within NNSA with a unique security structure and program. 
Page 4 GAO-03-471 Nuclear Security 

Site Operations in Texas, the Savannah River Site6 and the Savannah River 

Site Office in South Carolina, and Lawrence Livermore National 

Laboratory and the Livermore Site Office in California. At each location 

we met with both federal and contractor officials and obtained pertinent 

supporting documentation. 

To determine how NNSA sites prepare and document corrective action 

plans and related analyses, we examined 43 closed and open corrective 

action plans dated from 1999 through 2002 that we selected at random 

from each of the 6 NNSA sites (as well as the DOE Savannah River Site, 

which is expected to come under NNSA’s jurisdiction in the future) that 

contain category I special nuclear materials.7

 We reviewed these plans to 

determine the extent and type of analyses that support the corrective 

actions in the plans. These plans generally represent the contractors’ 

actions to address high priority findings in contractors’ security and 

safeguards program. To understand how the corrective action process 

currently works, we compared the processes in place at each NNSA site 

we visited during 2002. 

We performed our review from December 2001 through April 2003 in 

accordance with generally accepted government auditing standards. 

NNSA has not been fully effective in managing its safeguards and security 

program in four key areas, and therefore, it cannot be assured that its 

contractors are working to maximum advantage to protect critical 

facilities and material from individuals seeking to inflict damage. The 

following four areas are key: 

• Defining clear roles and responsibilities. Since its creation in March 

2000, NNSA’s management structure has been in a state of flux. While 

in December 2002, NNSA issued what it considers final directives for 

reorganizing headquarters and site offices, NNSA expects it will take 

until at least September 2004 to fully implement its new management 

structure. In particular, NNSA is still defining its site offices’ roles and 

 6

 Although the Savannah River Site is still an Environmental Management designated site, 

according to site officials, it will likely become an NNSA site once the accelerated cleanup 

is complete. Because of its present role as a key DOE nuclear weapons production site, we 

included it in our review of site offices. 

7

 One of the seven sites—Transportation Safeguards——is operated by NNSA, not a 

contractor. 

Results in Brief 
Page 5 GAO-03-471 Nuclear Security 

responsibilities for safeguards and security. Specifically, it is still 

developing the components of a Functions, Responsibilities, and 

Authorities Manual, which will not be completed for several months 

because of the highly detailed planning necessary for determining staff 

functions at the various sites. This manual, which NNSA itself 

recognizes as crucial, is intended to set out roles and responsibilities 

clearly. This still-developing management structure led to confusion 

about the roles and responsibilities of the headquarters and site offices. 

• Assessing sites’ security activities. Without a functional management 

structure and with ongoing confusion about roles and responsibilities, 

inconsistencies have emerged among the NNSA sites on how to 

conduct key aspects of safeguards-and-security assessment activities. 

In particular, three out of the seven NNSA site offices use the 

traditional survey approach, as required by DOE policy, to oversee 

security activities, while four have discontinued surveys and instead 

rely on surveillance activities. The distinction between these two 

activities is important: A survey provides a comprehensive annual 

review, by a team of experts from throughout NNSA, of contractor 

safeguards and security and generally takes about 2 weeks. In contrast, 

surveillance relies on a single or small number of NNSA site officials 

overseeing one or more aspects of a contractor’s safeguards and 

security activities throughout the year. However, officials from DOE’s 

Office of Security—which developed the policy for conducting 

surveys—believe the surveillance model does not comply with the DOE 

order because it does not provide a comprehensive overview. 

Furthermore, officials from DOE’s Office of Independent Oversight and 

Performance Assurance and NNSA headquarters expressed concern 

about the site offices’ ability to conduct surveillance because of 

shortfalls in available expertise. The four site offices have been able to 

operate using only surveillance activities because, during the 

reorganization of the management structure, NNSA has not issued 

guidance on complying with DOE policy for conducting surveys. 

• Overseeing contractors’ corrective actions. NNSA contractors do not 

consistently conduct the analyses DOE policy requires in preparing 

corrective action plans, compounding the problems in ensuring 

physical security. Inconsistency occurs because the NNSA site officials 

do not have implementation guidance from headquarters on how to 

address corrective actions. Of the 43 corrective action plans we 

reviewed for 1999 through 2002, less than half showed that the 

contractor had performed the required root cause analysis. 

Furthermore, less than 25 percent demonstrated that the contractor 

had performed a required risk assessment or cost-benefit analysis. As a 
Page 6 GAO-03-471 Nuclear Security 

result, potential opportunities to improve physical security at the sites 

are not maximized because corrective actions are developed without 

fully considering the problems’ root causes, risks posed, or cost versus 

benefit of taking corrective action. However, at the 7 sites we visited in 

2002, the site offices and contractors are making some progress to 

establish formal processes for root cause and other analyses. 

Nevertheless, inconsistencies remain regarding the approaches used to 

complete these analyses. For example, some site processes specify that 

root cause analyses will be conducted for all corrective action plans, 

while other sites consider the completion of these analyses optional. 

An NNSA headquarters official stated that the agency expects to issue 

additional guidance for implementing DOE security policies in 2003. 

• Allocating staff. NNSA has shortfalls at its site offices in the total 

number of staff and in areas of expertise, which could make it more 

difficult for the site offices to oversee safeguards and security 

effectively and to ensure that the agency fully knows security 

conditions at its sites. According to officials at 5 of the 7 site offices we 

visited, they have, or expect to have, an average of 2 to 6 vacancies per 

site for overseeing contractors’ safeguards and security; typically, each 

site expects to have 10 to 14 security-related positions within the next 2 

years. The vacancies occur, in part, because staff are reluctant to move 

to locations they view as less desirable and because NNSA has frozen 

hiring in response to budget constraints. Some of these vacancies are 

for specialists in particular subject areas, such as Industrial Security 

Systems—a key specialty needed for conducting physical security 

inspections. The lack of expertise and staff could be further 

complicated for some sites by NNSA’s realignment plan. Under this 

plan, NNSA expects to streamline federal oversight of contractors and 

reduce headquarters and field staff by 20 percent by the end of fiscal 

year 2004. Site officials said that they will fill some vacancies through a 

virtual organization in which experts at other locations will assist with 

certain components of the surveillance activities. However, it will take 

time to work through some of the difficulties associated with making 

the transition to this approach. 

We are making recommendations to the Secretary of Energy and the 

Administrator of the NNSA that are intended to place additional focus on 

key management and oversight dimensions during NNSA’s ongoing 

reorganization. 

In commenting on our draft report, NNSA concurred with two of our four 

recommendations, disagreed with one, and did not indicate agreement or 

disagreement with the fourth. NNSA concurred with our recommendation 
Page 7 GAO-03-471 Nuclear Security 

to formally establish roles and responsibilities, and it plans to issue a 

formal document in 2003. NNSA also concurred that corrective action 

plans must be prepared in accordance with established standards and 

policy. NNSA disagreed with the conclusion that it was not ensuring the 

comprehensive annual assessments of contractors’ performance that DOE 

policy requires. NNSA believed that its surveillance activities were also 

comprehensive; however, NNSA provided no evidence—such as 

implementation guidance to the sites that are conducting surveillances—

that would ensure that the sites’ surveillance activities conform to DOE’s 

policies. Finally, regarding our recommendation that NNSA develop and 

implement a plan for effectively allocating staff for safeguards and security 

oversight, NNSA commented that managers have staffing plans and that its 

virtual organization and additional hiring will address sites’ need for 

certain types of skilled personnel. In our view, while reliance on the virtual 

approach may be effective in the short term, the continuing vacancies at 

some sites indicate that NNSA may have difficulty attracting and retaining 

necessary expertise at specific, understaffed locations over the long term. 

Since its creation in 1977, DOE has been responsible for developing, 

producing, and maintaining nuclear weapons; preventing the proliferation 

of weapons of mass destruction; designing, building, and maintaining 

naval nuclear propulsion systems; and ensuring the security of the nuclear 

weapons complex. In 2000, however, the Congress created a separately 

organized agency within DOE—the NNSA.8

NNSA’s Office of Defense Nuclear Security is primarily responsible for 

developing the agency’s security programs, including protecting, 

controlling, and accounting for material and ensuring physical security for 

all facilities in the complex. Historically, NNSA has conducted 

comprehensive annual surveys of contractors’ operations for safeguards 

and security. These surveys, which can draw upon subject matter experts 

throughout the complex,9

 generally take about 2 weeks to conduct and 

cover 5 “topical” areas and 32 subtopical areas. The topical areas include 

 8

 National Defense Authorization Act for Fiscal Year 2000, Pub. L. No. 106-65, tit. 32 (also 

known as the National Nuclear Security Administration Act). 

9

 The core skill sets needed to address the safeguards and security elements at a facility 

include program management and planning; protective force operations; classified matter 

protection and control; physical security; technical security and security systems; nuclear 

material control and accountability; and safeguards and security program infrastructure. 

Background 
Page 8 GAO-03-471 Nuclear Security 

program management, protection program operations, information 

security, nuclear materials control and accountability, and personnel 

security. The survey team assigns ratings of satisfactory, marginal, or 

unsatisfactory. Currently, NNSA’s facilities have been rated satisfactory in 

most topical areas. All deficiencies (findings) identified during a survey 

require the contractors to take corrective action, and both findings and 

corrective actions are to be entered in the Safeguards and Security 

Information Management System—a DOE-wide, integrated tracking 

database for findings of surveys and other safeguards and security 

activities. 

In addition, NNSA’s Office of Facilities and Operations is expected to 

provide policy guidance for safeguards and security. This office is also 

expected to be responsible for the Nuclear Safeguards and Security 

Program, which oversees the implementation of safeguards and security in 

NNSA facilities. The office is expected to integrate and defend the budget 

for safeguards and security to ensure that program components can 

achieve mission objectives. Through various contract mechanisms, NNSA 

provides financial incentives, such as award fees, for contractor 

performance. NNSA assesses this performance based on the extent 

contractors meet a set of measures, which are generally established in 

annual performance plans—so-called performance measures. 

DOE’s Office of Independent Oversight and Performance Assurance 

supports NNSA in safeguards and security assessments and conducts 

independent oversight activities in line with DOE and NNSA policies and 

priorities. Among other things, the office is responsible for evaluating the 

effectiveness of contractors’ performance in safeguards and security. To 

carry out this function, this office periodically assesses both federal and 

contractor operations at a site and identifies findings, issues, and 

opportunities for improvement. It also performs follow-up reviews to 

ensure corrective actions are effective and that weaknesses in safeguards 

and security are appropriately addressed. 
Page 9 GAO-03-471 Nuclear Security 

NNSA has not been fully effective in managing its safeguards and security 

program in four key areas, and therefore, it cannot be assured that its 

contractors are working to maximum advantage to protect its sites. First, 

NNSA has not fully defined safeguards and security roles and 

responsibilities. Second, without an effective management structure, site 

offices are uncertain about how to conduct their safeguards and security 

responsibilities. This uncertainty has resulted in inconsistencies in how 

site offices comply with DOE orders in assessing contractors. Third, even 

when assessments are done, NNSA contractors do not consistently 

conduct required DOE analyses in preparing corrective action plans. 

Finally, NNSA’s shortfalls at its site offices in the total number of staff and 

expertise could make it more difficult for the site offices to oversee 

safeguards and security effectively. 

Since its creation in March 2000, NNSA’s management structure has been 

in a state of flux, and NNSA expects it will take at least to September 2004 

to implement a new management structure. However, NNSA needs a 

stable structure to establish clear roles and responsibilities for its 

headquarters and site offices, including safeguards and security oversight. 

In May 2001, NNSA’s Administrator proposed a management structure for 

his organization,10 but in December 2001, we reported that a clearly 

delineated overall management structure still did not exist.11 In February 

2002, NNSA reported in more detail to Congress on its outline for a new 

management structure12 to improve NNSA’s effectiveness and efficiency. 

NNSA expected to implement the new structure later in the year. 

Since then, NNSA headquarters and field officials have been defining 

safeguards and security roles and responsibilities. In December 2002, 

NNSA fundamentally changed the management structure for safeguards 

and security. It abolished operations offices, which had been responsible 

for conducting the annual, comprehensive surveys as well as other 

 10 National Nuclear Security Administration, Report to Congress on the Plan for 

Organizing the National Nuclear Security Administration (Washington, D.C.: May 3, 

2001). 

11 U.S. General Accounting Office, NNSA Management: Progress in the Implementation of 

Title 32, GAO-02-93R (Washington, D.C.: Dec. 12, 2001). 

12 National Nuclear Security Administration, Report to Congress on the Organization and 

Operations of the National Nuclear Security Administration (Washington, D.C.: Feb. 25, 

2002). 

NNSA’s Lack of 

Safeguards and 

Security Direction in 

Key Areas Results in 

Inconsistent 

Management of 

Contractors 

NNSA Has Not Clearly 

Defined Roles and 

Responsibilities, Resulting 

in Confusion at Sites 
Page 10 GAO-03-471 Nuclear Security 

safeguards and security activities. It divided these operations offices’ 

responsibilities among the site offices and a service center, formerly the 

Albuquerque operations office; headquarters will oversee the performance 

of the site offices. The restructuring brings day-to-day federal oversight of 

laboratories and plants closer to the site offices. However, these changes 

do not complete the management structure. NNSA plans to further 

streamline its oversight of contractors by reducing site activities. Among 

other things, NNSA plans to focus more on ensuring that contractors’ 

management systems are valid. Furthermore, NNSA plans to review its 

policies and practices and decide which site office oversight activities can 

be reduced or eliminated in order for the site offices to work more 

efficiently. It has not yet identified which specific activities will be 

modified. At the time of our review, headquarters could not provide details 

on how it intends to monitor the NNSA site offices’ performance with 

respect to safeguards and security or address deficiencies. 

In creating this new management structure, NNSA has not yet developed a 

Functions, Responsibilities, and Authorities Manual (FRAM), an 

organizational tool used by managers at federal agencies, including DOE, 

for defining roles and responsibilities. This manual is to address the 

functions, responsibilities, and authorities of all elements within NNSA. 

NNSA headquarters security officials agree that this guidance is crucial 

and stated that they are currently developing the components of a FRAM, 

which should be finalized in 2003. NNSA told us that completing the FRAM 

takes significant time because of the highly detailed planning necessary for 

determining staff functions at the various sites. 

According to NNSA site office officials, as they wait for formal guidance 

from headquarters on conducting security oversight, each office is 

carrying out oversight activities as it deems appropriate. In addition, these 

officials told us that they have not received formal notification about the 

change in their safeguards and security oversight responsibilities, such as 

responsibilities for the survey program. Officials at several site offices 

expressed frustration with this lack of direction. 

NNSA site offices are not consistent in how they assess contractor 

safeguards and security activities, and they may not be conducting these 

assessments in accordance with DOE policy. The lack of consistency and 

the failure to implement DOE policy occurs in part because the site offices 

have had to assume new oversight responsibilities without, among other 

things, clear guidance from headquarters on how to carry out these 

responsibilities. As a result, three offices of the seven NNSA site offices we 

NNSA’s Security 

Assessment Processes 

Differ among Sites and Are 

Inconsistent with DOE 

Requirements 
Page 11 GAO-03-471 Nuclear Security 

visited continue to use the traditional survey approach to oversee security 

activities (Oak Ridge, Savannah River, and NNSA’s Office of 

Transportation Safeguards), while the remaining four have adopted or are 

adopting a surveillance model—-Amarillo, Kirtland, Livermore, and Los 

Alamos. The distinction between these two activities is important: A 

survey provides a comprehensive annual review, by a team of experts, of 

contractor safeguards and security and generally takes about 2 weeks; 

formerly, the operations offices generally conducted surveys, assisted by 

experts from throughout the complex, as necessary. In contrast, 

surveillance relies on a single or small number of NNSA site officials 

overseeing one or more aspects of a contractor’s safeguards and security 

activities throughout the year, and the documentation from a surveillance 

or a group of surveillance activities may be used as part of the survey. 

By relying on surveillance, NNSA may have less assurance that it fully 

knows the condition of security at its sites and therefore potentially 

cannot act to correct deficiencies undisclosed by this limited review. 

Surveillance allows subject matter experts at the sites to evaluate areas of 

contractor safeguards and security performance more often than the 

traditional survey process and therefore potentially identify deficiencies 

faster. However, according to DOE officials, reliance on surveillance is not 

consistent with DOE orders calling for a comprehensive survey of a 

contractor’s safeguards and security performance. This survey provides a 

unified assessment of all security-related topical areas.13 Officials from 

DOE’s Office of Security—which developed the policy for conducting 

surveys—believe the surveillance model does not comply with DOE order 

survey requirements because it is not comprehensive. Officials from DOE’s 

Office of Independent Oversight and Performance Assurance expressed 

concern about the site offices’ ability to conduct surveillance because of 

shortfalls in available expertise. Furthermore, the director of NNSA’s 

Office of Defense Nuclear Security acknowledged that although some 

NNSA site offices, such as the Los Alamos site office, are using the 

surveillance model, this site and others lacked the necessary personnel to 

conduct surveillance. 

According to officials from DOE’s Office of Independent Oversight and 

Performance Assurance and one site office, surveillance is not compatible 

with the current Safeguards and Security Information Management 

 13 The frequency of survey schedules can be modified if the site being surveyed meets 

certain criteria. 
Page 12 GAO-03-471 Nuclear Security 

System, a DOE information database system used to track findings and 

associated corrective actions, and therefore could pose problems for sites 

in entering information. On the other hand, NNSA officials at site offices 

and headquarters argue that using the surveillance model for oversight will 

produce an annual end of the year survey report and should have the same 

end result as an annual survey. However, NNSA could have difficulty 

ensuring consistent and comprehensive assessments because of the 

difficulties posed by using the surveillance model without appropriate 

NNSA-wide implementation guidance, site office staffing shortfalls, and 

database compatibility problems. 

Contractors have not consistently prepared effective, formal root cause 

analyses in developing corrective action plans for identified deficiencies, 

as DOE policy requires.14 An effective, formal, root cause analysis can 

enhance the development of corrective actions, as we observed while 

reviewing some plans. However, less than half of the 43 corrective action 

plans we reviewed, dated between 1999 and 2002, showed that the 

contractor had performed the required root cause analysis. Furthermore, 

in a few cases corrective action plans were based on root cause analyses 

that were poorly prepared, resulting in confusion and contradictions. For 

example, NNSA had identified a deficiency at one site of potential entry 

into a critical facility. The contractor did not fully develop a root cause for 

this problem but merely rebutted the finding’s validity. Nevertheless, the 

contractor took a corrective action in response to this deficiency—

spending about $150,000. However, because the root cause analysis was 

not fully developed, we could not determine how, or if, the contractor’s 

corrective actions would correct the deficiency. Furthermore, the 

contractor’s staff preparing the analysis did not have formal training in 

how to conduct root cause analyses. NNSA site officials agreed that the 

root cause analysis was performed incorrectly and that their oversight 

review of the analysis had not detected this problem. 

Despite the problems some contractors have had in preparing root cause 

analyses, corrective action processes in 2002 at all 7 sites showed that 

some sites are making progress. For example, in late 2000, the Office of 

Transportation Safeguards, which is responsible for securely transporting 

critical NNSA items and material, had begun to correct significant 

weaknesses in its process for preparing and tracking corrective actions. 

 14 DOE Order 470.1 Safeguards and Security Program; Sept. 28, 1995. 

NNSA’s Corrective Action 

Practices Are Inconsistent 

with DOE Requirements 
Page 13 GAO-03-471 Nuclear Security 

According to an official responsible for corrective actions at the office, the 

new process has already resulted in documented improvements to the 

quality and completeness of its corrective action plans. For example, the 

new process for root cause analyses identified additional reasons for a 

recurring NNSA finding on problems in how three federal agent facilities 

in NNSA’s Office of Transportation Safeguards inspected the vehicles used 

to transport critical materials across the nation. These inspections are 

crucial in preventing individuals from attaching explosives or other foreign 

devices to the vehicles in potential attempts at sabotage or theft. The new 

process enabled NNSA to identify specific actions to ensure consistent 

interpretation and implementation of vehicle inspection procedures 

among the three facilities. Because the finding has not been repeated since 

July 2000, it appears that the additional corrective actions proved 

effective. Another site, Sandia National Laboratories, has developed a 

process for root cause analysis that other sites may find useful. Sandia 

uses a designated root cause analyst to systematically lead teams of 

subject matter experts at the laboratory through the steps for determining 

root cause. With this expert in root cause analyses, Sandia helps ensure 

that these analyses are consistent and effective. 

Other analyses and assessments that are critical to planning corrective 

actions are also not consistently prepared at NNSA sites. In particular, less 

than 25 percent of the corrective action plans we reviewed showed 

documentation of other analyses required by the DOE order for corrective 

action, such as risk assessment or cost-benefit analysis. Without this 

documentation, we found it difficult to determine what process, if any, the 

sites had used to determine the risk level of the problem or the cost and 

relative benefit of implementing corrective actions. 

Consistency problems are likely to continue without effective NNSA 

guidance for corrective actions. For example, at four sites we visited, the 

sites either did not require a risk assessment and cost-benefit analyses or 

stated that they were optional, depending on the site’s evaluation of the 

need for an analysis. However, the remaining three sites we visited 

required these analyses for all corrective action plans. This inconsistency 

resulted in part from differing interpretations of the DOE order governing 

corrective actions. As a result, NNSA cannot be assured that all 

contractors are considering the costs of corrective actions in conjunction 

with the risk posed or the potential benefits to be gained. NNSA officials at 

some sites stated that, without implementation guidance, the intent of the 

DOE order requiring these analyses can be interpreted differently from site 

to site, which contributes to the inconsistent practices we observed. Since 

we provided our draft report to NNSA in April 2003, it has sent a brief 
Page 14 GAO-03-471 Nuclear Security 

guidance letter on corrective action plans to its site offices, clarifying its 

analysis and documentation requirements. An NNSA headquarters official 

stated that issuance of additional guidance for implementing DOE security 

policies is expected in 2003. 

And finally, NNSA sites do not consistently measure all performance 

aspects of contractors’ preparation of corrective action plans and may 

reward contractors simply for closing the finding on schedule. According 

to our review of performance measures concerning corrective actions, 

four of the six contractor-operated sites we visited had measures that 

were primarily based on whether the contractor met the schedule for 

completing corrective actions, not on whether and how well the 

contractor had performed the analyses.15 The other two sites did not 

consider any corrective action performance measures in assessing 

contractor performance—not even the schedule. However, DOE guidance 

encourages sites to measure qualitative factors, whenever possible, to 

minimize the need to rely solely on schedule-driven measures.16 Effective 

qualitative performance measures would essentially reflect how well the 

contractor completes root cause analyses, risk assessment, and costbenefit analyses. 

The lack of qualitative performance measures affects the quality of the 

correction plan. For example, in fiscal year 1999, DOE’s Office of 

Independent Oversight and Performance Assurance criticized a site that 

had schedule-driven performance measures for poorly prepared corrective 

action plans. Out of the 50 plans reviewed for that site, 27 had inadequate 

root cause determinations, and 15 had corrective actions that were 

unlikely to fix the deficiency cited. The performance measures in place for 

this contractor in fiscal year 1999—and then again in fiscal years 2000 and 

2001—did not reflect qualitative aspects of these analyses; instead, they 

were primarily focused on schedule-driven outcomes. Some contract 

provisions permit the contractor to forfeit some of the award fee based on 

other generic performance factors, such as “management failure.” 

However, these generic provisions may not be fully effective in motivating 

contractors in all aspects of their corrective action performance because 

 15 One site, the Office of Transportation Safeguards is federally operated and therefore 

performance award fees are not applicable. 

16 U.S. Department of Energy, Guidelines for Performance Measurement, DOE G 120.1-5 

(Washington, D.C.: June 30, 1996). 
Page 15 GAO-03-471 Nuclear Security 

these provisions are not explicitly focused on corrective action and are 

therefore not highly visible. 

NNSA’s site offices have shortfalls in the total number of staff and in the 

expertise for effectively overseeing contractors, including covering all 

topical areas in the annual surveys. At five of the seven sites we visited, 

NNSA officials told us that they currently have, or will have, two to six 

vacancies in safeguards and security positions once NNSA fully 

implements its new management structure; each site believes that it needs 

from 10 to 14 security-related positions in order to carry out its oversight 

activities under NNSA’s new organization. In particular, some of the site 

offices are experiencing difficulty in filling positions because some staff 

consider the site locations less desirable than others and because NNSA 

has instituted a hiring freeze. Some of these vacancies are for specialists in 

particular subject areas, such as industrial security systems—a key 

specialty needed for conducting physical security inspections. Officials in 

the Office of Independent Oversight and Performance Assurance 

concurred that NNSA’s reorganization and the shifting of responsibilities 

to the site offices has the potential to weaken security oversight. 

To offset the lack of some subject matter experts at sites, NNSA field 

officials indicated that they frequently rely on subject matter experts from 

headquarters or other site offices to cover site offices that do not have 

expertise locally. With only a limited number of subject matter experts in 

the complex, the sites have to coordinate oversight carefully. Coordination 

is particularly complicated at those sites that have switched to a 

surveillance model since they may have to rely on particular subject 

expertise that is only available during certain times. 

NNSA’s new management structure further complicates the problems in 

staff allocation. NNSA expects to reduce headquarters and field staff by 20 

percent by the end of fiscal year 2004. In this restructuring, NNSA plans to 

share staff expertise, creating a “virtual” organization to cover the needs of 

site offices and other areas within the complex until a final move of 

personnel can be made. Headquarters officials told us that it may take 1 to 

2 years to move the appropriate safeguards and security persons to the 

areas where they are needed. Until then, they expect the virtual 

organization to meet the complex’s needs. The virtual organization will 

include subject matter experts whose knowledge will be needed 

throughout the nuclear weapons complex and not just at their current 

sites. Some of these experts will work from the service center or be 

detailed to site offices as needed. With competing demands for the 

Difficulties in Allocating 

Staff Could Hinder 

Effective Safeguards and 

Security Oversight 
Page 16 GAO-03-471 Nuclear Security 

experts, it is unclear how they will successfully provide assistance to site 

offices in their surveillance processes. The assistance may be unavailable 

when needed since components of surveillance are ongoing and may span 

an entire year. 

Without effectively managing its safeguards and security program, NNSA 

cannot be assured that its contractors are working to maximum advantage 

to protect its nuclear weapons sites. These sites may have critical 

materials that could be prime terrorist targets. Several factors contribute 

to this lack of assurance. NNSA continues to change its management 

structure, making it difficult to define roles and responsibilities clearly. 

Without a functional management structure, some site offices and 

contractors may not be carrying out their security responsibilities, as DOE 

orders require. In particular, NNSA has not fully assured itself that the four 

sites that rely on surveillance activities, rather than on the DOE-required 

surveys, are overseeing contractors’ security activities in the integrated, 

comprehensive fashion that are called for in the annual surveys. Moreover, 

when NNSA site offices allow and reward contractors for closing findings 

without ensuring that the contractors have correctly identified the root 

cause, assessed risk, and conducted a cost-benefit analysis, NNSA cannot 

be assured that the security problem identified was adequately addressed. 

Finally, to provide effective oversight, NNSA needs to develop an 

approach, beyond its “virtual” organization, that ensures its limited 

security resources are able to provide oversight, over the long term, where 

and when it is needed. 

In order to strengthen the safeguards and security program of the nuclear 

weapons complex, we recommend that the NNSA Administrator and 

Secretary of Energy 

• formalize the roles and responsibilities of site offices and headquarters 

for conducting oversight; 

• ensure that sites are performing oversight using a survey approach that 

provides an integrated comprehensive view of security conditions and 

is consistent with DOE orders; 

• ensure that contractors’ corrective action plans are prepared and 

documented consistently and are based on qualitative root-cause, riskassessment, and cost-benefit analyses, and that appropriate incentives 

are used to help motivate contractors toward effectively addressing 

findings; and 

Conclusions 

Recommendations for 

Executive Action 
Page 17 GAO-03-471 Nuclear Security 

• develop and implement a plan to ensure that NNSA allocates 

safeguards and security staff so that it provides effective safeguards 

and security oversight over the long term. 

We provided the DOE’s NNSA with a draft of this report for review and 

comment. Overall, NNSA concurred with two of our four 

recommendations, disagreed with one, and did not indicate agreement or 

disagreement with the fourth. In the area of concurrence, NNSA concurred 

with our recommendation to formally establish roles and responsibilities, 

and it plans to do so in 2003. NNSA also concurred that corrective action 

plans must be prepared in accordance with established standards and 

policy and based on documented root cause analysis, risk assessments, 

and cost-benefit analysis. Since we provided our draft report to NNSA, it 

has sent its site offices a guidance letter on corrective action plans that 

clarifies its analysis and documentation requirements. NNSA now allows 

required elements to be omitted from corrective action plans, but only if 

the contractors document the rationale for the exclusion as a formal part 

of their plan. We believe this guidance letter is a positive step in clarifying 

some implementation aspects of the DOE requirements, and we encourage 

continued management attention to this area. NNSA did not comment on 

the portion of this recommendation concerning the use of appropriate 

incentives to motivate contractors to address findings effectively. 

NNSA disagreed with the conclusion that led to our recommendation to 

conduct oversight using a survey approach, which provides an integrated, 

comprehensive view of security conditions and is consistent with DOE 

orders. Specifically, NNSA disagreed with our conclusion that it was not 

ensuring the comprehensive annual assessments of contractors’ 

performance that DOE policy requires. As we reported, four of the seven 

site offices no longer conduct comprehensive, integrated surveys to assess 

security but instead rely on surveillance activities. NNSA believed that 

these surveillance activities were also comprehensive; however, NNSA 

provided no evidence—such as implementation guidance to the sites that 

are conducting surveillances—that would ensure that the sites’ 

surveillance activities conform to DOE’s policies. Without such guidance, 

NNSA cannot be fully assured that surveillance activities, as presently 

conducted, provide the comprehensive assessment DOE requires in its 

surveys. Our recommendation therefore is intended to focus NNSA 

management attention on ensuring that site offices conduct security 

assessments that are integrated, comprehensive, and on par with the 

survey approach previously used and currently described in DOE orders. 

Furthermore, NNSA asserted, incorrectly, that we found its security 

Agency Comments 

and Our Evaluation 
Page 18 GAO-03-471 Nuclear Security 

posture to be at risk. Assessing NNSA’s security posture was not the 

objective of this report. Rather, our objective was to assess the way NNSA 

manages its overall security program. We have clarified the report, where 

appropriate. 

Finally, regarding our recommendation that NNSA develop and implement 

a plan to ensure that it effectively allocates staff to provide safeguards and 

security oversight, NNSA commented that managers have staffing plans 

and that its virtual organization and additional hiring will address sites’ 

need for certain types of skilled personnel. Reliance on the virtual 

approach may be effective in the short term. However, the continuing 

vacancies at some sites indicate that NNSA may have difficulty attracting 

and retaining necessary expertise at specific, understaffed locations over 

the long term. NNSA’s comments do not indicate that it fully understands 

the need to address this longer-term problem. We have modified our 

recommendation to target this specific long-term concern. 

We modified our report, where appropriate, to reflect NNSA’s comments 

and to clarify some of our conclusions. NNSA’s comments on our draft 

report are presented in appendix I. 

As arranged with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after the 

date of this letter. At that time, we will send copies of the report to the 

Secretary of Energy, the Administrator of NNSA, the Director of the Office 

of Management and Budget, and appropriate congressional committees. 

We will make copies available to others on request. In addition, the report 

will also be available at no charge on the GAO Web site at 

http://www.gao.gov. 
Page 19 GAO-03-471 Nuclear Security 

If you or your staff have any questions about this report, please call me at 

(202) 512-3841. Major contributors to this report are listed in appendix II. 

Sincerely yours, 

Robin M. Nazzaro 

Director, Natural Resources 

 and Environment 
Appendix I: Comments from the National 

Nuclear Security Administration 

Page 20 GAO-03-471 Nuclear Security 

Appendix I: Comments from the National 

Nuclear Security Administration 
Appendix I: Comments from the National 

Nuclear Security Administration 

Page 21 GAO-03-471 Nuclear Security 
Appendix I: Comments from the National 

Nuclear Security Administration 

Page 22 GAO-03-471 Nuclear Security 
Appendix II: GAO Contact and Staff 

Acknowledgments 

Page 23 GAO-03-471 Nuclear Security 

James Noel (202) 512-3591 

In addition to the individual named above, Christopher R. Abraham, Jill 

Berman, Jonathan M. Gill, Andrea R. Miller, Christopher M. Pacheco, and 

Carol Herrnstadt Shulman made key contributions to this report. 

Appendix II: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Acknowledgments 

(360159) 
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